DCT

2:24-cv-01007

Granite Vehicle Ventures LLC v. Tesla Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-01007, E.D. Tex., 02/19/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Texas corporation, making it a resident of all judicial districts within the state, and because Defendant maintains regular and established places of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicles equipped with its Full Self-Driving (FSD) (Supervised) software infringe three patents related to systems and methods for controlling the driving modes of self-driving vehicles.
  • Technical Context: The technology at issue involves decision-making systems in autonomous vehicles that determine whether the vehicle should operate in an autonomous or manual mode by assessing factors such as vehicle faults, environmental conditions, and the competence of both the vehicle's processor and the human driver.
  • Key Procedural History: The complaint states that the asserted patents, originally assigned by the inventors to IBM, were subsequently transferred through a series of assignments to Daedalus Group LLC, Slingshot IOT LLC, and ultimately to the Plaintiff, Granite Vehicle Ventures LLC.

Case Timeline

Date Event
2015-09-25 Earliest Priority Date for '402, '765, and '004 Patents
2016-10-01 Accused Tesla vehicles equipped with FSD-capable hardware begin shipping
2023-03-07 U.S. Patent No. 11,597,402 Issues
2023-08-29 U.S. Patent No. 11,738,765 Issues
2024-07-16 U.S. Patent No. 12,037,004 Issues
2025-02-19 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,597,402, “Controlling Driving Modes of Self-Driving Vehicles,” issued March 7, 2023

The Invention Explained

  • Problem Addressed: The patent background describes the need for systems to control whether a self-driving vehicle (SDV) operates in an autonomous mode or a manual mode controlled by a human driver (Compl. ¶45; ’402 Patent, col. 1:26-30). The implicit technical challenge is managing this control transfer safely and effectively based on dynamic conditions.
  • The Patented Solution: The invention proposes a system that compares the relative capabilities of the vehicle's onboard control processor and the human driver to handle a given situation. It determines a "control processor competence level" and a "human driver competence level" based on current operational anomalies and selectively assigns control of the vehicle to whichever is deemed more competent ('402 Patent, Abstract; Fig. 5).
  • Technical Importance: This approach provides a dynamic, context-aware framework for managing the crucial human-machine interface in semi-autonomous vehicles by making a comparative assessment of which controller—human or machine—is better suited for the current circumstances (Compl. ¶45; ’402 Patent, col. 9:8-13).

Key Claims at a Glance

  • The complaint asserts independent claim 4 and alleges infringement of "claim 1 et seq." (Compl. ¶¶50, 167).
  • Independent Claim 4 (System Claim) Elements:
    • A self-driving vehicle (SDV) comprising a sensor system, vehicle controls, and a computer system.
    • The computer system is capable of receiving sensor readings and operating the vehicle controls.
    • The computer system is capable of determining the SDV's operational state and any vehicle fault.
    • The computer system is capable of determining a "competence level of the processor".
    • The computer system is capable of determining a "competence level of a human driver".
    • The computer system is capable of determining a corrective action "using the competence level of the processor and the competence level of the human driver".
    • The computer system is capable of implementing the corrective action and issuing an alert indicating it.

U.S. Patent No. 11,738,765, “Controlling Driving Modes of Self-Driving Vehicles,” issued August 29, 2023

The Invention Explained

  • Problem Addressed: As with the related ’402 Patent, the invention addresses the control handoff between autonomous systems and human drivers in an SDV ('765 Patent, col. 1:26-30).
  • The Patented Solution: This patent claims a computer program product that executes a method for responding to specific faults. The system receives sensor readings (including from a GPS sensor), determines if a fault related to a "current weather condition" has occurred, and assesses if it "exceeds a threshold for danger." If it does, the system consults a "fault-remediation table" to determine a corrective action, which comprises transferring control to the human driver and issuing an immediate alert ('765 Patent, Claim 1).
  • Technical Importance: This patent describes a more structured approach than the general comparative framework of the ’402 Patent, using a predefined table to map specific environmental faults to predetermined, safety-oriented corrective actions, aiming for predictable system responses ('765 Patent, col. 8:30-46).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and alleges infringement of "claim 1 et seq." (Compl. ¶¶76, 180).
  • Independent Claim 1 (Computer Program Product Claim) Elements:
    • A method comprising receiving sensor readings that describe an SDV's operational state.
    • Determining if a "fault" has occurred and if it exceeds a "threshold for danger".
    • Determining a corrective action using a "fault-remediation table".
    • The SDV implementing the corrective action.
    • The method further specifies the fault comprises a "current weather condition", determining the danger threshold involves assessing a "control processor competence level", and the corrective action involves transferring controls to manual and alerting the driver to "take over immediately".

Multi-Patent Capsule: U.S. Patent No. 12,037,004

  • Patent Identification: U.S. Patent No. 12,037,004, “Controlling Driving Modes of Self-Driving Vehicles,” issued July 16, 2024 (Compl. ¶42).
  • Technology Synopsis: This patent claims a computer program product that uses sensor readings (steering wheel, speedometer, GPS, camera) to determine a human driver's competence level. This level is compared against a first and second threshold to identify a "first fault" (e.g., minor inattention) or a "second fault" (e.g., prolonged inattention). A "fault remediation table" is then used to implement distinct corrective actions for each fault, such as a warning for the first fault and decreasing speed and transferring control for the second fault ('004 Patent, Claim 1).
  • Asserted Claims: Claim 1 is asserted in the complaint (Compl. ¶109).
  • Accused Features: The complaint alleges that Tesla's FSD system monitors driver attentiveness and compares it against multiple thresholds to trigger tiered responses, from initial warnings ("first corrective action") to system disengagement ("second corrective action") (Compl. ¶¶140-150).

III. The Accused Instrumentality

  • Product Identification: The Accused Products are Tesla's FSD (Supervised) software and all Tesla vehicles compatible with it, including the Model 3, Model S, Model X, Model Y, and Cybertruck models manufactured since 2016 (Compl. ¶46).
  • Functionality and Market Context: The FSD (Supervised) software is described as a SAE Level 2 driver-assist system that requires active driver supervision at all times (Compl. ¶37). The system utilizes a suite of cameras and sensors to create a model of the vehicle's surroundings, which is processed by a specialized "FSD Computer" running neural networks to make driving decisions (Compl. ¶¶53, 57). A key function is monitoring driver attentiveness through a cabin-facing camera and sensors on the steering wheel; if the driver is deemed inattentive, the system issues escalating warnings and may ultimately disengage FSD (Compl. ¶¶38, 66-67). The complaint alleges the FSD feature is instrumental to Tesla's competitive advantage and is offered as an $8,000 one-time purchase or a $99 monthly subscription (Compl. ¶¶33, 36, 53).

IV. Analysis of Infringement Allegations

11,597,402 Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
a sensor system comprising a plurality of sensors The vehicles include cameras, ultrasonic sensors, and optionally radar to monitor the surrounding area. A visual from the owner's manual shows the placement of these sensors (Compl. p. 14). ¶54 col. 6:39-40
vehicle controls comprising: engine throttle, steering mechanism, and braking system The vehicles include an accelerator pedal, brake pedal, and steering wheel, which are controlled by the FSD system in autonomous mode. A diagram from the owner's manual identifies these interior controls (Compl. p. 15). ¶56 col. 6:41-44
a computer system comprising a processor... The vehicles include a "Full Self-Driving (FSD) Computer" that runs the FSD software. ¶57 col. 3:21-24
the computer system is capable of determining a competence level of the processor The system determines its own competence is insufficient in non-ideal conditions, such as snow, and issues an alert that FSD may be degraded. ¶64 col. 10:9-15
the computer system is capable of determining competence level of a human driver The system uses a combination of a steering wheel sensor and an interior-facing cabin camera to monitor driver attentiveness and distraction. ¶66 col. 10:52-57
the computer system is capable of determining a corrective action using the competence level of the processor and the competence level of the human driver The system determines to issue warnings when either the driver is detected to be distracted or when the processor's competence is degraded due to poor weather. ¶70 col. 11:19-24
the computer system is capable of implementing the corrective action If the driver ignores warnings and remains inattentive, the system suspends FSD for the remainder of the drive. The complaint includes a screenshot showing the "Autosteer unavailable for the rest of this drive" message (Compl. p. 22). ¶74 col. 12:1-4
the computer system is capable of issuing an alert indicating the corrective action When the driver is inattentive, the system issues an audible and visual warning to "Please pay attention to the road" (Compl. p. 23). ¶75 col. 12:10-14
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether a SAE Level 2 "supervised" system, which requires constant driver engagement by definition, can be considered an "SDV" operating in an "autonomous mode" as contemplated by the patent (Compl. ¶¶37, 45).
    • Technical Questions: The claim requires determining a corrective action using both the processor and driver competence levels. The complaint alleges the system issues warnings based on either low driver competence or low processor competence (Compl. ¶70). This raises the question of whether the system performs the claimed comparative or combined assessment, or if it simply reacts to independent triggers.

11,738,765 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
determining a corrective action... using a fault-remediation table The complaint alleges that FSD uses a neural network for decision-making, and that this process is "akin to cross-referencing a table in a database." ¶¶92, 95 col. 8:30-32
the SDV implementing the corrective action When FSD becomes unavailable due to a fault, the system sounds a warning chime and displays a "Take over Immediately" instruction (Compl. p. 30). ¶97 col. 8:1-4
wherein, the fault comprises a current weather condition of the roadway... The complaint alleges that in poor weather conditions, the Accused Products may alert that FSD is "degraded" or prompt the driver to take over. ¶100 col. 9:45-49
determining whether the fault exceeds a threshold for danger comprises determining a control processor competence level It is alleged the system weighs sensor data to determine the processor's competence level, which is deemed low in complex situations or when data is unintelligible, leading to a determination that the danger threshold is exceeded. ¶102 col. 10:9-15
the corrective action comprises transferring driver controls to manual control and alerting a human driver to take over immediately In certain situations, such as poor weather or sun glare, the system disengages and presents a visual and audible alert for the driver to "take over immediately." ¶105 col. 7:40-44
  • Identified Points of Contention:
    • Scope Questions: The infringement theory may depend heavily on whether a "neural network" can be construed as a "fault-remediation table." A neural network operates as a complex, trained model making probabilistic predictions, whereas the patent describes the table in terms of discrete rows and columns for specific faults and corresponding actions, suggesting a deterministic lookup structure (Compl. ¶¶92, 95; '765 Patent, col. 8:30-46).
    • Technical Questions: Does the accused system identify the "weather condition" itself as the "fault," as required by the claim, or does it identify the effect of the weather (e.g., sensor obstruction, poor lane visibility) as the fault? The complaint alleges the former, but the evidence cited may only support the latter (Compl. ¶100).

V. Key Claim Terms for Construction

  • Term 1: "competence level" (of the processor/of a human driver) (’402 Patent)

    • Context and Importance: This term is the foundation of the '402 Patent's claimed invention, which relies on a comparative assessment of these two levels. The viability of the infringement allegation will depend on whether Tesla's system of monitoring for discrete events (e.g., driver inattention, sensor degradation) can be characterized as determining a "competence level."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes competence in general terms related to how well the controller handles the vehicle in terms of "safety, cost, consistency, etc." ('402 Patent, col. 10:27-30). This language may support a broader, qualitative assessment.
      • Evidence for a Narrower Interpretation: The specification provides specific, quantitative examples for determining competence, such as reviewing historical data on "accident frequency, travel speed, stopping and starting, gas mileage, etc." ('402 Patent, col. 10:17-27). This could support an interpretation requiring a data-driven, historical performance score rather than a real-time state assessment.

  • Term 2: "fault-remediation table" (’765 and ’004 Patents)

    • Context and Importance: This term is a critical limitation in both the '765 and '004 patents. Plaintiff's infringement theory characterizes a neural network as being "akin to" a table (Compl. ¶95). Practitioners may focus on this term because the technical difference between a neural network and a lookup table is substantial.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint itself provides the broadest possible interpretation by equating a complex predictive model with a table. The patent does not appear to offer intrinsic support for such a broad reading.
      • Evidence for a Narrower Interpretation: The specification describes the table with structural language: "where each row refers to a fault condition, a first column refers to a condition that gets manifested by that fault, and a second column... refers to the mode in which the vehicle should be driven" ('765 Patent, col. 8:30-38). This language strongly suggests a structured data format, like a database or lookup table, rather than a neural network.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all three patents, asserting that Tesla encourages infringement by advertising the FSD features, manufacturing and selling the vehicles with the software installed, and providing user manuals and software updates that instruct on the use of the accused functionality (Compl. ¶¶169-170, 182-183, 195-196).
  • Willful Infringement: Willfulness is alleged for all three patents based on Tesla's awareness of the patents and the infringement allegations "at least by the filing date of this Complaint" (Compl. ¶¶171, 184, 197). This frames the willfulness claim as being based on post-suit conduct.

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can the term "fault-remediation table," which the patent specification describes with the characteristics of a structured lookup table, be construed broadly enough to read on the accused FSD system’s use of a complex, probabilistic neural network for decision-making?
  • A key evidentiary question will be one of functional operation: does the accused FSD system actually perform the claimed step of comparatively assessing a "competence level" of the human driver against a "competence level" of the processor to determine which is superior, or does it employ a different logic, such as reacting to independent, predefined triggers for driver inattention and system degradation?
  • A foundational question will be one of system classification: does a SAE Level 2 driver-assist system, which is explicitly "Supervised" and requires the human driver to be fully engaged and ultimately responsible at all times, fall within the scope of the patents' claims directed to a "self-driving vehicle" that operates in an "autonomous mode"?